Pierson v. Commissioner
United States Tax Court
1. In 1923 the petitioner's grandfather created trusts in which petitioner's father had a remainder interest. The father died in 1925 and by will gave the petitioner a half interest in the remainder. The other half interest he gave to the petitioner's mother.
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1. In 1923 the petitioner's grandfather created trusts in which petitioner's father had a remainder interest. The father died in 1925 and by will gave the petitioner a half interest in the remainder. The other half interest he gave to the petitioner's mother. The petitioner acquired her mother's half interest by will in 1940. The life tenant died in 1941. In the period 1932 to 1941 the trustee in taxable transactions had acquired properties different from those originally transferred in trust. These properties were transferred to the petitioner by the trustees together with cash under a court…
1Opinion of the Court
FINDINGS OF FACT AND OPINION.
Tietjens, Judge:
The Commissioner determined deficiencies in the petitioner’s income tax as follows:
Year Deficiency
1944_1_$44, T99.17
1945_ 13.12
Certain adjustments made by the Commissioner are not contested by the petitioner. There are three issues for decision. The first involves the question of whether gain or loss was realized by the petitioner when she received certain assets from a trust in settlement of an inherited remainder interest in the trust; the second involves the determination of the petitioner’s basis in those assets; and third, whether the…
2Cases cited4 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Maguire v. CommissionerSupreme Court of the United States · 1941
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
3Cited by22 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Miriam Coward Pierson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Second Bank-State Street Trust Co. v. State Tax CommissionMassachusetts Supreme Judicial Court · 1958
- Drown v. United StatesDistrict Court, S.D. California · 1962
- Barrett v. CommissionerUnited States Tax Court · 1996
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